CDER
Report to the Nation: 2003
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2 Drug Safety and Quality
Index
Highlights
The practical size of premarketing clinical trials means
that we cannot learn everything about the safety of a drug
before we approve it. Therefore, a degree of uncertainty
always exists about the risks of drugs. This uncertainty
requires our continued vigilance, along with that of the
industry, to collect and assess data during the
post-marketing life of a drug.
We monitor the quality of marketed drugs and their
promotional materials through product testing and
surveillance. As Americans are increasingly receiving the
benefits of important new drugs before they are available to
citizens of other countries, we must be especially vigilant
in our surveillance. In addition, we develop policies,
guidance and standards for drug labeling, current good
manufacturing practices, clinical and good laboratory
practices and industry practices to demonstrate the safety
and effectiveness of drugs.
Highlights of drug safety and quality activities in 2003
include:
- Processing and evaluating 370,887 reports of adverse
drug events, including 29,955 submitted directly from
individuals.
- Reviewing about 3,000 reports of medication errors,
half of which are due to error-prone labeling.
- We held a public workshop to gather consumer and
scientific input on our proposals for risk management
strategies during drug development and after a drug is
marketed.
- Signing a cooperative research and development
agreement to develop advanced software tools for
quantitative analysis of drug safety data.
- Proposing a regulation that calls for over-the-counter
medicines commonly used in hospitals and all
prescription medicines to have a bar code. The rule
became final in 2004.
- Issuing 737 letters to help ensure that the promotion
of drug products presents a fair balance of risks and
benefits and isn’t false or misleading.
- Clarifying our policy on prescription drugs that are
sold without a prescription and providing an incentive
to have them incorporated into the U.S. drug regulatory
system.
- Developing technology for the rapid identification of
counterfeit drug products.
- Conducting shelf-life extensions for stockpiled drugs.
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Types of Risks from Medicines
Product quality defects. These are controlled through
good manufacturing practices, monitoring and surveillance.
Known side effects. Predictable adverse events are
identified in the drug's labeling. These cause the majority
of injuries and deaths from using medicines. Some are
avoidable, and others are unavoidable.
In many cases drug therapy requires an
individualized treatment plan and careful monitoring.
Other avoidable side effects are known drug-drug
interactions.
Unavoidable. Some known side effects occur with the
best medical practice even when the drug is used
appropriately. Examples include nausea from antibiotics or
bone marrow suppression from chemotherapy.
Medication errors. For example, the drug is
administered incorrectly or the wrong drug or dose is
administered.
Remaining uncertainties. These include unexpected
side effects, long-term effects and unstudied uses and
populations. For example, a rare event occurring in fewer
than 1 in 10,000 persons won't be identified in normal
premarket testing.
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Drug Safety
We evaluate the safety of drugs available to American
consumers using a variety of tools and disciplines. We
maintain a system of postmarketing surveillance and risk
assessment programs to identify adverse events that did not
appear during the drug development process. We monitor
adverse events such as adverse reactions, drug-drug
interactions and medication errors.
We have access to commercial databases that contain
non-patient-identifiable information on the actual use of
marketed prescription drugs in adults and children. This
dramatically augments our ability to determine the public
health significance of adverse event reports we receive.
As we discover new knowledge about a drug’s safety
profile, we make risk assessments and decisions about the
most appropriate way to manage any new risk or new
perspective on a previously known risk. Risk management
methods may include new labeling, drug names, packaging,
“Dear Health Care Practitioner” letters, education or
special risk communications, restricted distribution
programs or product marketing termination.
Risk management public workshop, concept papers
We held a three-day public workshop to discuss
risk-management activities in April 2003. Before the
workshop, we issued three concept papers for discussion:
- Premarketing Risk Assessment
- Risk Management Programs
- Risk Assessment of Observational Data: Good Pharmacovigilance
Practices
The concept papers, presentations and transcripts of the
workshops served as the basis for draft guidances issued in
May 2004 at http://www.fda.gov/bbs/topics/news/2004/new01059.html.
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Adverse Event Reporting System
A powerful drug safety tool is the Adverse Event
Reporting System. This computerized system combines the
voluntary adverse drug reaction reports from MedWatch and
the required reports from manufacturers. These reports often
form the basis of “signals” that there may be a
potential for serious, unrecognized, drug-associated events.
When a signal is detected, further testing of the hypothesis
is undertaken using various epidemiological and analytic
databases, studies and other instruments and resources. AERS
offers paper and electronic submission options,
international compatibility and pharmacovigilance screening.
Adverse event reporting
In 2003, we received 370,887 reports of suspected
drug-related adverse events:
- 22,955 MedWatch reports directly from individuals.
- 144,310 manufacturer 15-day (expedited) reports.
- 58,998 serious manufacturer periodic reports.
- 144,624 nonserious manufacturer periodic reports.
- nonserious).
Report types
- Direct reports from MedWatch.
An individual,
usually a health care practitioner, notifies us directly
of a suspected serious adverse event.
15-day (expedited) reports. Manufacturers report
serious and unexpected adverse events to us as soon as
possible but within 15 days of discovering the problem.
Manufacturer periodic reports. These report all
other adverse events, such as those less than serious or
described in the labeling. These are submitted quarterly for
the first three years of marketing and annually after that.
Nonserious reports are displayed separately starting with
1998
Electronic submissions
AERS was designed and implemented so that the majority of
the reports would be entered electronically. We are in the
process of migrating the reporting format from paper to
electronic. In a pilot program, we are accepting electronic
individual case safety reports from six major drug firms.
Electronic submissions into AERS represent 21 percent of the
total expedited reports we received in 2003. We estimate the
cost of receiving a report is reduced at least 30 percent
per report for those submitted electronically.
AERS on Internet
You can learn more about the Adverse Event Reporting
System at http://www.fda.gov/cder/aers/default.htm.
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MedWatch Outreach and Reporting
We administer the MedWatch program that helps promote the
safe use of drugs by:
- Rapidly disseminating new safety information on the
Internet and by providing e-mail notification to health
professionals, institutions, the public and our MedWatch
partners consisting of professional societies, health
agencies and patient and consumer groups.
- Providing a mechanism for health professionals and the
public to voluntarily report serious adverse events,
product quality problems and medication errors for all
FDA-regulated medical products. Reports can be filed by
mail, fax, telephone or the Internet. Direct reports,
primarily from healthcare professionals, have increased
by 51 percent from 1998 to 2003.
- Educating health professionals and consumers about the
importance of recognizing and reporting serious adverse
events and product problems, including medication
errors. Our education program includes Internet
outreach, speeches, articles and exhibits.
Individual healthcare professional and consumer
subscribers to our e-mail notification service increased to
more than 40,000. We also have 170 MedWatch Partner
organizations. Last year, These individuals and groups
received:
- 33 safety alerts for drugs.
- 25 to 45 safety-related labeling changes for drugs
each month.
MedWatch drug safety Internet resources
The latest medical product safety information can be
found at http://www.fda.gov/medwatch/.
You can sign up for immediate e-mail notification of
MedWatch safety information at http://www.fda.gov/medwatch/elist.htm.
Data mining
We signed a two-year data mining cooperative research and
development agreement with a commercial firm to develop
advanced software tools for quantitative analysis of drug
safety data. Data mining for simple drug-event signal
generation is one part of the potential contribution data
mining and related quantitative methods can make to increase
our awareness and understanding of trends and patterns in
adverse drug reactions.
Drugs with special safety restrictions
Controls on 10 prescription drugs include limiting
distribution to specific facilities; limiting prescription
to physicians with special training or expertise; or
requiring certain medical tests with their use. Consumers
should not buy these drugs over the Internet. As of April
30, 2003, these drugs are:
- Alosetron
- Bosentan
- Clozapine
- Dofetilide
- Fentanyl citrate
- Isotretinoin
- Mifepristone
- Sodium oxybate
- Thalidomide
- Trovafloxacin mesylate or alatrofloxacin mesylate
injection
More information is at http://www.fda.gov/oc/buyonline/consumeralert120902.html.
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Medication Guides
We may require specific written patient information for
selected prescription drugs that pose a serious and
significant public health concern. This information is
called a Medication Guide. Medication Guides must be
distributed to patients with each prescription dispensed. We
require Medication Guides when the information is necessary
for patients to use the product safely and effectively or to
decide whether to use or to continue to use the product.
Last year, we approved Medication Guides for one innovator
product and generic lindane and isotretinoin products:
- Mefloquine hydrochloride (Lariam).
- Lindane Shampoo
(generic product).
Lindane Lotion (generic product).
Isotretinoin (Claravis) and Isotretinoin (Sotret),
Medication Guide previously approved for Accutane and
Amnesteem.
Medication Error
Prevention
Avoiding name, label, packaging confusion
We work hard to ensure the safe use of drugs we approve
by weeding out brand names that look or sound like the names
of existing products. We identify and avoid brand names,
labels and packaging that might contribute to problems or
confusion in prescribing, dispensing or administering.
We review about 250 reports of medication errors each
month. About half are due to error-prone labeling such as
look-alike labels, poor package design and confusing names.
We provide a root cause analysis of these reports that may
result in revisions to the label, labeling, and/or packaging
of these products to avert further error.
Our comprehensive Web site on medication errors is at
http://www.fda.gov/cder/drug/MedErrors/default.htm.
Bar codes to be required on medicines in hospitals
In March 2003, we proposed a regulation that called for
over-the-counter medicines commonly used in hospitals and
all prescription medicines to have a bar code. The rule
became final in February 2004.
The bar-code rule aims to protect patients from
preventable medication errors by helping ensure that health
professionals give patients the right drugs at the
appropriate dosages and at the right time. The rule will
support and encourage widespread adoption of advanced
information systems that, in some hospitals, have reduced
medication error rates by as much as 85 percent.
We estimate that the rule will help prevent nearly
500,000 adverse events and transfusion errors while saving
$93 billion in health costs over 20 years.
DailyMed update
We are collaborating on a multi-agency effort to improve
patient safety through accessible medication information.
Called DailyMed and still in development, the project will
enable us-through the National Library of Medicine-to
provide an up-to-date electronic repository of medication
labeling in a standard format. This information will be
useable in computer systems that support patient safety,
such as electronic prescribing and decision-support systems.
Estrogen labeling safety changes
We made safety changes to the labeling of all estrogen
and estrogen with progestin products for use by
postmenopausal women to incorporate new risk information and
to emphasize individualized decisions that appropriately
balance the benefits and the potential risks of these
products. These changes, including a boxed warning, reflect
our analysis of the landmark Women’s Health Initiative
study, sponsored by the National Institutes of Health. The
study showed that postmenopausal women taking estrogen plus
progestin have an increased risk of heart attack, stroke,
breast cancer and blood clots. Complete information is at http://www.fda.gov/cder/drug/infopage/estrogens_progestins/default.htm.
Drugs with special safety
restrictions
Controls on 10 prescription drugs include limiting
distribution to specific facilities; limiting prescription
to physicians with special training or expertise; or
requiring certain medical tests with their use.
Consumers should not buy these drugs over the Internet.
As of April 30, 2003, these drugs are:
- Alosetron
- Bosentan
- Clozapine
- Dofetilide
- Fentanyl citrate
- Isotretinoin
- Mifepristone
- Sodium oxybate
- Thalidomide
- Trovafloxacin mesylate or alatrofloxacin mesylate
injection
More information is at http://www.fda.gov/oc/buyonline/consumeralert120902.html.
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Drug Shortages
We work to help prevent or alleviate shortages of
medically necessary drug products. Drug shortages occur for
a variety of reasons including manufacturing difficulties,
bulk supplier problems and corporate decisions to
discontinue drugs. Because drug shortages can have
significant public health consequences, we work with all
parties involved to make sure all medically necessary
products are available within the United States.
Drug shortage program aids counterterrorism effort
Utilizing data obtained from manufacturers and
distributors, our drug shortage program provides supply and
production information in response to federal government
requests in relation to counterterrorism efforts.
Drug shortageson the Internet
We have a Web site that lists current drug shortages,
describes efforts to resolve them and explains how to report
them.
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Drug Recalls
Drug recalls in fiscal year 2003
- 254 prescription drugs
- 88 over-the-counter drugs
In some cases, a drug product must be recalled due to a
problem occurring in the manufacture or distribution of the
product that may present a significant risk to public
health. These problems usually, but not always, occur in one
or a small number of batches of the drug. The most common
reasons for drug recalls include those listed in the column
at the left. In other cases, a drug is determined to be
unsafe for continued marketing and must be withdrawn
completely.
Manufacturers or distributors usually implement voluntary
recalls in order to carry out their responsibilities to
protect the public health when they need to remove a
marketed drug product that presents a risk of injury to
consumers or to correct a defective drug product. A
voluntary recall of a drug product is more efficient and
effective in assuring timely consumer protection than an
FDA-initiated court action or seizure of the product.
How we coordinate drug recalls
We coordinate drug recall information, assist
manufacturers or distributors in developing recall plans and
prepare health hazard evaluations to determine the risk
posed to the public by products being recalled.
We classify recall actions in accordance to the level of
risk. We participate in determining recall strategies based
upon the health hazard posed by the product and other
factors including the extent of distribution of the product
to be recalled.
We determine the need for public warnings and assist the
recalling firm with public notification about the recall.
Top 10 reasons for drug recalls in fiscal year 2003:
- cGMP deviations
- Subpotency
- Stability data does not support expiration date
- Generic drug or new drug application discrepancies
- Dissolution failure
- Label mix-ups
- Content uniformity failure
- Presence of foreign substance
- pH failures
- Microbial contamination of non-sterile products
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Safety-based Drug Withdrawals
No safety-based withdrawals in 2003
In some cases, there is an intrinsic property of a drug
that makes it necessary to withdraw the drug from the market
for safety reasons. There were no drugs withdrawn from the
U.S. market last year for safety reasons.
Record of safety-based market withdrawals
When drug withdrawals are compared based on year of
approval, the recent period when we applied user-fee review
goals is similar to the previous period.
Pre-PDUFA period. Between Jan. 1, 1971, and Dec. 31,
1993, we approved 477 new molecular entities, and 13 (2.7
percent) were eventually withdrawn. Nearly all the drugs we
approved in this period were received before we implemented
PDUFA review goals.
PDUFA period. Between Jan. 1, 1994, and April 30,
2004, we approved 303 NMEs, and 7 (2.3 percent) have been
withdrawn. Nearly all drugs we approved in this period were
reviewed under PDUFA goals.
Recent safety-based drug withdrawals
Drug name (year approved/year withdrawn)
- Phenylpropanolamine (-/2000) (never approved by FDA)
- Fenfluramine (1973/1997)
- Azaribine (1975/1976)
- Ticrynafen (1979/1980)
- Zomepirac (1980/1983)
- Benoxaprofen (1982/1982)
- Nomifensine (1984/1986)
- Suprofen (1985/1987)
- Terfenadine (1985/1998)
- Encainide (1986/1991)
- Astemizole (1988/1999)
- Flosequinan (1992/1993)
- Temafloxacin (1992/1992)
- Cisapride (1993/2000)
- Dexfenfluramine (1996/1997) (not an NME)
- Bromfenac (1997/1998)
- Cerivastatin (1997/2001)
- Grepafloxin (1997/1999)
- Mibefradil (1997/1998)
- Troglitazone (1997/2000)
- Rapacuronium (1999/2001)
- Alosetron* (2000/2000)
*Returned to market in 2002 with restricted
distribution.
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Drug Promotion Review
Drug promotion review statistics
We issued a total of 737 drug promotion letters last
year.
- 42 regulatory action letters
- 185 launch campaigns
- 510 advisory acknowledgement or closure letters
The information about a drug available to physicians and
consumers is just as important to its safe use as drug
quality. We promote and protect the health of Americans by
ensuring that drug advertisements and other promotional
materials are truthful and balanced. We operate a
comprehensive program of education, surveillance and
enforcement about drug advertising and promotion.
Launches and advisories
When requested, we review advertisements and other
promotional materials before drug companies launch marketing
campaigns that introduce new drugs or campaigns that
introduce new indications or dosages for approved drugs. In
calendar year 2003, we issued 185 advisory letters to
companies regarding their promotional materials for launch
campaigns.
We issued 346 other advisory letters to the industry
regarding proposed promotional pieces, both professional and
consumer directed. In addition, we issued 159 other types of
correspondence to the pharmaceutical industry, such as
letters of inquiry, closure letters or acknowledgement
letters.
Regulatory actions
We issued 42 regulatory action letters to companies for
prescription drug promotions determined to be false,
misleading, lacking in fair balance of risks and benefits or
that promoted a product or indication before approval. These
were either “untitled” letters for violations or
“warning” letters for more serious or repeat violations.
Examples of specific types of violative promotions include
promotional exhibit hall displays, oral representations,
Internet sites, plus traditional materials such as journal
advertisements and sales brochures.
Direct-to-consumer promotion
Included in our letters were 254 regarding
direct-to-consumer promotion. This compares with 188 letters
in 2002. Included in last year’s letters were 47 for
launch campaigns and 163 for non-launch advisories. Ten were
regulatory letters.
We are working on improving our oversight of DTC
advertising. Evidence from our own studies as well as those
conducted by consumer groups and other entities consistently
shows that DTC ads encourage some patients to seek care for
undertreated conditions. This often results in a different
treatment that is more appropriate for the patient than the
advertised drug. But physicians and others are concerned
that consumers may not always get a balanced view of the
benefits and risks of a product.
DTC advertising surveys
We completed two national telephone surveys and conducted
preliminary analyses. One survey of 943 consumers is a
follow-up to the 1999 survey of patients’ attitudes and
behaviors associated with direct-to-consumer advertisements.
The other is a new survey of 500 physicians’ attitudes and
behaviors associated with direct-to-consumer advertisements.
Preliminary findings of the two surveys indicate that:
- About 40 percent of patients and about 45 percent of
physicians feel DTC advertising encourages information
seeking about potentially serious medical conditions.
- About 80 percent of patients and 70 percent of
physicians feel DTC advertising creates awareness of new
treatments.
- About 42 percent of patients and 75 percent of
physicians feel DTC advertising make it seem that the
drug will work for everyone or make the patients think
the drug works better than it does.
- About 40 percent of physicians believe that patients
understand the possible risk and negative effects of
drugs, compared to 80 percent who believe patients
understand the benefits and positive effects.
- Slightly less than half (47%) of physicians report
feeling at least a little pressure to prescribe when
asked for a prescription.
More is available at http://www.fda.gov/cder/ddmac/globalsummit2003/index.htm.
DTC public meeting
To explore DTC advertising issues, we held a two-day
public meeting where we presented information from our two
patient and one physician surveys. We heard from researchers
who have investigated the promotion of prescription drugs
directed to consumers through print, broadcast and other
types of media.
DTC letters
- 2003: 254
- 2002: 188
- 2001: 190
- 2000: 215
- 1999: 247
- 1998: 282
- 1997: 240
Proposed rule to revise prescription drug labeling
We continued to work on a final rule, based on comments
from the public to our proposal in 2001. The main purpose of
labeling is to communicate essential information about
prescription drugs to health care providers.
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Drug Product Quality
We provide comprehensive regulatory coverage of the
production and distribution of drug products. We manage
inspection programs designed to minimize consumer exposure
to defective drug products. We have two basic strategies to
meet this goal:
- Evaluating the findings of inspections that examine
the conditions and practices in plants where drugs are
manufactured, packed, tested and stored.
- Monitoring the quality of finished drug products in
distribution, through sampling and analysis.
We identify, evaluate and analyze inspection findings for
trends in deficiencies. We develop guidances to assist drug
manufacturers in gaining a better understanding of our
regulations. We communicate the expectations of compliance
through outreach programs. We review and evaluate for
regulatory action all reports of FDA inspections of foreign
drug manufacturing facilities. We determine which foreign
manufacturers are acceptable to supply active pharmaceutical
ingredients or finished drug products to the U.S. market.
Reporting systems for drug quality problems
Two important post-marketing tools help us rapidly
identify significant health hazards and quality problems
associated with the manufacturing and packaging of drugs:
- Drug Quality Reporting System.
Through MedWatch
,
we receive reports of observed or suspected drug
quality defects associated with marketed drugs. We
evaluate and prioritize the reports to determine potential
health hazards and industry trends. These reports
significantly assist us in targeting potential
manufacturing quality problems and identifying candidates
for further sampling and analysis. We identify significant
health hazards associated with drug manufacturing,
packaging and labeling and initiate field inspection
assignments. We review inspection reports and recommend
appropriate corrective action. We maintain a central
reporting system to detect problem areas and trends.
Field Alert Reports. Firms are required to notify
FDA promptly of possible problems that may represent safety
hazards for their marketed drug products. FDA’s district
offices evaluate these reports and conduct follow-up
inspections. We review and evaluate the inspection findings
to determine if firms are complying with reporting
requirements. We review and approve enforcement
recommendations for failure to meet these requirements.
Misbranded drugs, unsubstantiated claims
Mislabeled, fraudulent, hazardous products. We often
encounter mislabeled and fraudulent products that make
unsubstantiated claims. Consumers may use these products
inappropriately or incorrectly. They may use a fraudulent
product for treating a serious disease condition in place of
an effective treatment or delay the use of effective
treatment. For these reasons, products that are mislabeled,
fraudulent or make unproven claims may pose a significant
health risk.
Occasionally, fraudulent products may also contain toxic
compounds that are likely to cause serious illness or
injury. In addition, the marketing of products that lack
required FDA approval threatens to undermine the U.S. drug
development and approval process as well as the ongoing
over-the-counter drug review process.
Protecting consumers from misbranded or fraudulent drugs
We protect consumers from mislabeled, fraudulent or
hazardous products. We locate and identify these products
for sale on the Internet as well as from traditional retail
outlets, and we take steps to remove them from the market.
These steps include issuing enforcement letters and pursuing
enforcement actions, such as seizures of violative products
and injunctions against firms or individuals.
International commerce in pharmaceuticals continues to be
an important regulatory topic. We work with the FDA field
force to implement legal requirements establishing which
drugs may be imported by manufacturers, distributors and
consumers.
We protect the public health by ensuring that imported
drugs are not counterfeit and meet applicable legal
requirements relating to safety and effectiveness.
Risk-based surveillance sampling of drugs
We monitor the quality of the nation’s drug supply
through surveillance and sampling of foreign and domestic
finished dosage forms and bulk shipments of active
ingredients.
The drug products surveyed are selected according to a
risk-based strategy that targets products with the greatest
potential to harm the public health. FDA district offices
conduct follow-up inspections to determine the cause of
sample failures and to assure corrective action by the
firms.
Sampling criteria
- Microbial/endotoxin concerns
- Stability concerns
- Sterility issues
- Dissolution issues
- Impurities/contaminants
- Product quality history
- Counterfeit drugs
- History of violations
Prescription drugs sold without approved applications
We identify drugs that are marketed without an approved
new or generic drug application. We estimate that there are
several thousand illegally marketed drug products in the
United States, comprising several hundred unique molecules.
We issued a draft guidance in October that describes how we
intend to:
- Exercise our enforcement discretion regarding these
products.
- Provide an incentive to be the first manufacturer to
obtain approval for one of these drugs. After a grace
period, we will consider taking enforcement action
against unapproved competitors, which may result in de
facto exclusivity.
- Avoid unnecessarily restricting patient access to
useful medicines.
- Reiterate our risk-based criteria for enforcement
action.
Manufacturing plant inspections
Preapproval inspections
During fiscal year 2003, FDA evaluated:
- 589 plants in support of new drug applications
- 864 domestic firms in support of generic drug
applications
Good manufacturing practice inspections
- There were 1,512 good manufacturing practice
inspections in fiscal year 2003.
- We reviewed 51 field recommendations for regulatory
action and approved 34. These included 27 warning
letters, four injunctions and three seizures.
- We reviewed 184 foreign establishment inspection
reports, resulting in one warning letter and one import
alert.
FDA field offices conduct inspections of domestic and
foreign plants that manufacture, test, package and label
drugs. Before a drug is approved, FDA investigators must
determine if data submitted in the firm's application are
authentic and if the plant is in compliance with good
manufacturing practices. After a drug is approved, FDA
conducts periodic inspections to make sure a firm can
consistently manufacture the product with the required
quality. We develop compliance programs to guide the
investigators in conducting these inspections, and we
identify facilities that are high priority for inspection
based on their identified risk potential.
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Drug Product
Quality Science
Process analytical technologies initiative
Our goal for this initiative is to facilitate the
introduction of new and emerging technologies that will
improve the capability and efficiency of the pharmaceutical
manufacturing process while maintaining or improving product
quality. Known as process analytical technologies (PAT),
these are systems for continuous analysis and control of
manufacturing processes based on real-time or rapid
measurements during processing. They can also be
non-destructive. These systems involve in-line, on-line or
at-line monitoring, measuring and controlling in manufacture
of drug substance and drug products.
We are using a collaborative process to develop this
initiative. We are bringing together experts in the areas of
analytical and physical chemistry, pharmaceutical
technology, regulatory compliance, chemical engineering and
international pharmaceutical manufacturing. These include
experts from industry and academia along with our own and
those from other FDA components.
We are encouraging the adoption of this technology in
drug manufacturing because it can enhance process
understanding, improve overall product quality and lead to
increased efficiencies. This also addresses many of the
objectives of the Pharmaceutical cGMPs for the 21st Century
Initiative.
A steering committee comprised of senior FDA managers is
involved in the development of a general guidance on the use
of these new technologies. A special review team is now in
place to evaluate process analytical technologies as the
pharmaceutical industry begins implementation in existing
and new manufacturing processes. On the team, our own
chemistry reviewers and compliance officers will join FDA's
field investigators on inspections.
By organizing public meetings and workshops, we have
gathered information related to development and use of
process analytical technologies and shared our own research
data.
We entered into a a cooperative research and development
contract with a major pharmaceutical company to develop and
implement chemical imaging as a process analytical
technology tool.
FDA’s effort to facilitate the introduction of new
technologies to the manufacturing sector of the
pharmaceutical industry now has its own Web page at http://www.fda.gov/cder/OPS/PAT.htm.
Laboratory support
We assessed several analytical technologies for
characterizing active pharmaceutical ingredients and
guarding against counterfeit product marketing. We applied
near infrared, Raman, Isotope ratio mass spectrometry to the
problem of distinguishing between production sources of
active pharmaceutical ingredients and finished dosage forms.
We developed methodology to better characterize nasal spray
products. We evaluated a new aerodynamic particle size
analyzer. We evaluated instrumentation for the determination
of particle size and particle size distribution for
cyclosporin drug products. We are developing physicochemical
methods to assess quality changes in liposomal drug
products.
Microbiology
We assess product sterility, maintenance of product
safety and the microbiological controls used by firms for
drug development and manufacturing. Our microbiology review
assures the safety of sterile and non-sterile products
through scientific evaluation and communication with the
industry and assures consistency through guidance documents.
We promote the development of uniform and practical test
methods and criteria for our own use and through the U.S.
Pharmacopoeia and the International Conference on
Harmonization. We have a new program to advance rapid
microbiology test methods.
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Date created: May 24, 2004